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It could be difficult - see a similar question posted above with the heading "Late implementation."
It might depend on the specific ways in which the original plan was different from the EPA standards, and whether it can be shown that no significant impacts occured before the updated plan was put in place. For example, if the previous period was during a dry season, or local conditions prevented runoff from reaching any streams or stormwater drains, you might be able to make a effective case. To be more sure, you'll want to submit a CIR.
Thank you David. You've raised good points and given me a better idea on how to address this particular documentation. And yes, I second your conclusion that a CIR may be unavoidable here. I'll post any updates on this for the benefit of this forum.
Thanks again.
Esteban.
Hi Esteban,
How did you go with this? Did you submit the CIR? I have a somewhat similar situation...
Thank you for your time!
Well, seems this is a common question we all have, I have a similar situation, any updates or success stroies through a late LEED decision?
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